“I am confident in the safety of the food I eat.” Five years ago, only one-third of U.S. consumers strongly agreed with this statement. While they held the government primarily responsible for food safety, followed by food companies and farmers, when it came to trusting them, farmers were third, federal regulators were eighth, and food companies were eleventh. And we in food safety wonder why consumers don’t always adhere to good food safety practices or follow label instructions. How can food safety experts from government, industry and academia communicate with consumers in a meaningful way? How can we convey that just because something can happen, the likelihood that it will happen varies? And how can we convince consumers to take steps to reduce their risk of foodborne illness?

The 2023 virtual Food Safety Forum, organized by the American Frozen Food Institute (AFFI), will address these questions and more. Taking place Sept.13 and free to attend, the Food Safety Forum is taking a deep dive into the state of risk communications. Science is complicated. Consumers want simple, unambiguous answers, and misinformation is abundant. Effective communication is hard and communicating public health risk — the likelihood that one will get sick, not to be confused with hazards — is an ongoing challenge. 

Like it or not, food safety professionals are risk communicators. Family and friends often ask for my opinion when they see alarming headlines about the safety of our food supply. On a broad scale, scientists are seldom viewed as great communicators and most of us are not trained that way. But facts and data don’t speak for themselves. Most consumers prefer a “tell me what to do” approach rather than delve into the complexities of contamination rates and dose responses. AFFI’s Food Safety Forum is bringing together the right group of experts from diverse backgrounds to address these topics with the goal of communicating in a way that improves public health. 

Perhaps the most notable component of the Food Safety Forum is the breadth of stakeholders from industry, government, academia and consumer groups, that all see the need for better communication of food safety risks. Many of these groups, historically viewed as adversaries, have common goals: we all want safe food and for consumers to view and act on food safety risks appropriately. The collaboration and diversity of partners for this year’s Food Safety Forum are unprecedented.

The event will kick off with the well-known Don Schaffner of Rutgers University discussing the “Current Reality of Risk Communication.” As co-host of the “Risky or Not” podcast, Don is perfectly positioned to talk about risk as distinct from hazards in a food safety context and how to explain these concepts to consumers.

No discussion of food safety communication would be complete without addressing the elephant in the room: lawyers. Whether it’s communicating about a serious outbreak, a recall that warrants immediate action or safe food handling practices, regulators are often criticized for being too slow, too fast and rash, too simplistic or too complicated. Elizabeth Fawell, an attorney with the Hogan Lovells law firm, will moderate a discussion with experts who know first-hand the challenges public health officials face when trying to clear food safety communications internally. Joining to share learnings from their experiences are Brian Ronholm with Consumer Reports, former deputy undersecretary for food safety with the U.S. Department of Agriculture’s Food Safety and Inspection Service (USDA FSIS), Roberta Wagner with the International Dairy Foods Association who formerly worked with the U.S. Food and Drug Administration and FSIS, and Frank Yiannas, former deputy commissioner at the FDA. 

Consumers are the ultimate target of food safety communications. When it comes to educating and empowering people to make informed decisions about food safety risks, the rubber meets the road for the scientific community. Who is better to address the consumer view than Mitzi Baum of STOP Foodborne Illness, who represents families of consumers impacted by foodborne illness? Joining Baum are Kristine Butler with FDA’s communications and public engagement team, Ben Chapman with North Carolina State University (and the other half of the “Risky or Not” podcast), and communications representatives from food retail and national food brands. Together, these communicators will speak to their mechanisms to earn trust and gain attention.

Finally, the Food Safety Forum will look to the future. How can risk communicators learn from previous missteps? How can we break through the noise? How can we narrow the gap between mitigating food safety hazards and communicating public health risks? Representatives from the Association of Food and Drug Officials, Consumer Reports, the Centers for Disease Control and Prevention and the food industry will discuss the lessons learned and what it means for the future of communicating food safety to consumers.

Moving the needle on consumer behavior is a lofty undertaking and discussion is needed on how to identify effective communication mechanisms and overcome barriers to meaningful communications. The collaborators convened by AFFI come from different perspectives but are united by their commitment to not only improve food safety, but to also improve consumer understanding of complex food safety topics so they can best protect their health. This topic is not going away. Attend this free event on Sept. 13 to learn more about current challenges and approaches for the future. Register now at www.affi.org/food-safety-forum.

About the author: Jennifer McEntire, Ph.D., is the Founder of Food Safety Strategy LLC. With 20 years of food and beverage association experience, she combines her technical background and regulatory insights to help the food industry assess and manage food safety risks in order to protect public health. McEntire earned a B.S. in food science from the University of Delaware and Ph.D. from Rutgers University as a USDA National Needs Fellow in food safety.

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The independent expert panel has been charged with evaluating the structure, leadership, authorities, resources and culture of the FDA’s human foods program.

FDA Commissioner Robert Califf announced the review in May while a congressional committee was questioning him about an outbreak of cronobacter infections linked to infant formula from Abbott Nutrition. The agency was under fire for their slow response and disorganization. Some people have called for a reorganization of top positions at the FDA. 

In the public meeting’s food safety session, six food safety experts from various fields provided feedback and suggestions for the FDA.

The Speakers:

• Bill Marler, JD, Marler Clark LLP, PS
• Mitzi Baum, MS, STOP Foodborne Illness
• Scott Faber, Environmental Working Group
• Jennifer McEntire, Ph.D., International Fresh Produce Association
• Caroline Smith DeWaal, EatSafe
• David Goldman, MD, MPH, formerly of FDA’s Office of Food Policy and Response

Bill Marler, JD, Marler Clark LLP, PS

Seattle food safety attorney Bill Marler explained that he’s spent nearly 30 years coming to D.C. from Washington state for discussions on how to make food safety perfect. But he implored the panel to “not make perfect the enemy of the good.”

Marler said that it is past time to address the fragmented and illogical division of federal oversight of food safety. “For decades multiple experts have cited the need to revamp the food safety and quality of the U.S. food supply,” Marler said. “I believe that FSMA’s (Food Safety Modernization Act) failures are not due to the legislation itself, but due to the lack of sustained consistent effective and accountable leadership at the FDA, due to the culture of fragmentation the essential food safety functions between the four main center.”

 In closing, Marler’s advice to the panel was to create separate commissioners in the FDA — one for food and one for drugs.

Mitzi Baum, MS, STOP Foodborne Illness

“I’m here on behalf of individuals and families that continue to be impacted by foodborne disease,” said Mitzi Baum, the chief executive officer at the Chicago-based organization STOP Foodborne Illness. With more than two decades of experience at Feeding America, including time as the non-profit’s director of food safety, Baum said that consumers are still waiting for a food safety culture shift from reactionary to preventive. She said this is evidenced in the powdered infant formula recall from Abbott Nutrition. “The culture remains reactive, the process lacks clarity and the system is not structured for swift urgent action to protect consumers.”

“Consumers want to trust that foods that they feed their families are safe.” Baum lists the slow implementation of FSMA, the same foods regularly being recalled and the ongoing powdered infant formula crisis as things impacting consumers’ trust and reasons why the FDA can’t be resistant to change. “The process that you (the foundation) have undertaken will have a meaningful impact on their (consumer) safety,” she told the panel. “Consumers can’t wait 88 years and continue to suffer the consequences of resistance to change.”

Scott Faber, Environmental Working Group

Scott Faber, Vice President for government affairs at the Environmental Working Group, made five key points. “One, it’s clear that FDA food program nutrition and food safety needs more resources and that user fees are essential to the program’s success.”

“Two, it’s equally clear that the fragmented leadership at the top of the FDA hampers FDA’s ability to make risk-based decisions about how to best deploy these resources.”

“Three, that the prevention mandate enshrined in FSMA has not been fully embraced by FDA especially by FDA inspectorate and FSMA’s command to protect consumers from pathogens and produce has simply been ignored.”

“Four, FDA has systematically failed to address the risks posed by food chemicals.”

“Five, Americans trust and respect FDA, but FDA must be much more transparent if the agency hopes to retain that trusted respect.”

Jennifer McEntire, Ph.D., International Fresh Produce Association

Jennifer McEntire, Chief Food Safety and Regulatory Officer at the International Fresh Produce Association, started by saying that having an empowered deputy commissioner for foods who truly understands the food system and has the authority to lead and coordinate the foods programs at the FDA will go a long way and would address many of the issues. 

McEntire added that the “FDA would benefit from a leader who can set direction, get people on board, look for partnerships and collaborations that can stretch and leverage those resources and occasionally make tough decisions.”

Caroline Smith DeWaal, EatSafe

Caroline Smith DeWaal, Deputy Director at EatSafe at Global Alliance for Improved Nutrition, wanted to make it clear that her comments reflect her own views not those of any organization where she currently works or previously worked. 

“I saw more clearly how the agency challenge really lies both in its leadership, but much more in its culture,” DeWaal explained. “The agency is set up with systems that devolve leadership and decision making to an absurd extent.” She said that this devolving of decision-making could be because of fear. “It’s fear of making a decision that could be criticized by the industry by the media, by other agencies in the federal government or even by FDA colleagues.”

Finally, she said, “To address the crisis at FDA, there is an urgent need to segregate and streamline the agency’s food safety functions, provide dedicated inspection and regulatory resources to the food program and provide a clear path for decision making, with a dedicated food safety professional at the top.”

David Goldman, MD, MPH, formerly of FDA’s Office of Food Policy and Response

The last of the six experts, Dr. David Goldman has 20-plus years of working in food safety with the USDA Food Safety and Inspection Service and recently with the FDA. “I think that my work at the two federal food regulatory agencies has provided me a rare perspective,” Goldman said. “I want to respectfully offer an insider’s perspective.”

Goldman suggested that the major challenge he observed in his time at the FDA was the fragmentation of roles and responsibilities that followed the reorganization in 2019. “At that time and several times after that, I made the observation that dotted lines on an org chart are very different than solid lines.”

He said he would favor a single food safety agency or a separate operating division that reports up to the secretary of the Department of Health and Human Services.

“I wanted to offer something that may be a little more practical, but yet is still bold. I think I propose that all the functions related to say, science, both research and regulatory lab operations, policy compliance, communications, response, consumer education and most importantly inspection, be placed under one roof in a new Center for Food Safety within the FDA.”

Goldman finished his recommendations by saying that his purposed structure would replicate the one that he worked under at FSIS, where everyone in their respective roles are focused solely on food safety.

About the foundation

According to its website, the Reagan-Udall Foundation for the Food and Drug Administration is an independent 501(c)(3) organization created by Congress “to advance the mission of the FDA to modernize medical, veterinary, food, food ingredient, and cosmetic product development, accelerate innovation, and enhance product safety.”

The Foundation embodies the FDA’s vision of collaborative innovation to address regulatory science challenges of the 21st century and assist in the creation of new, applied scientific knowledge, tools, standards, and approaches the FDA needs to evaluate products more effectively, predictably, and efficiently, and thereby enhance the FDA’s ability to protect and promote the health of the American public. The Foundation serves as a crucial conduit between FDA and the public, providing a means for FDA to interact directly with stakeholders, including industry and consumers. The Foundation does not participate in regulatory decision-making or offer advice to FDA on policy matters.

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Once the recommendations are in place, work toward implementation will begin, with the trade associations planning to tackle that step via corporate executive suites. Leaders of the Produce Marketing Association and the United Fresh Produce Association on Monday described the plans for the pursuit of the prevention of foodborne illnesses and faster responses when illnesses are detected.

The online session presented by the marketing association and the lobbying organization focused on romaine safety and three recent outbreaks, but it did not include any discussion of a fourth outbreak revealed this past week by the Food and Drug Administration. The multi-state outbreak ran from July to September.

Topics that were on the industry agenda Monday included the need for traceable information on romaine lettuce and other food; the potential impact animal feedlots have in the contamination of fresh produce crops and the water used on them; and how to change the system while protecting the entire industry as well as individual growers.  

The industry leaders also briefly discussed new agricultural water best practices recommendations that they plan to roll out in December. They did not provide specific details during the Monday event. Details are available on the organization websites.

One common thread through the presentations and across all topics is what the produce leaders described as a shared responsibility.

Bob Whitaker of the Produce Marketing Association said people who buy leafy greens should only do business with growers who participate in agreements that have self-imposed metrics, or rules, regarding food safety. 

In addition to the buyers having the responsibility, governmental entities that investigate outbreaks also have to do their part to help protect consumers, said Jennifer McEntire of United Fresh. She said the industry is helping government agencies like the Food and Drug Administration by developing spreadsheets for at-a-glance presentations of traceability information during investigations.

McEntire said there is so much information going to FDA’s investigators from businesses throughout the supply chain that there is “a lot of noise but very little sound.”

Whitaker said better cooperation and communication between government and industry are needed, not only for traceability but in general to keep things on track. He said if an investigation gets off track, it can be hard to get it back on track, especially with perishables. 

A key point in the plan to boost the safety of romaine lettuce and other leafy greens involves the close proximity of concentrated animal feeding operations (CAFOs) to fields where produce is grown. The outbreak strain of E. coli from the spring 2018 outbreak was found in canal water in the growing area. The open canal runs between a 100,000-plus head CAFO and lettuce fields.

Whitaker said initially CAFOs were not in the mix when the industry mitigation task force got to work in 2018. Now, he said, growers and others know the feedlots need to be in the equation, but there isn’t data to support action. 

Two organizations that impose procedures on their members — the California and Arizona Leafy Greens Marketing Agreements (LGMAs) — have already increased the minimum distance between the edge of a feedlot and the edge of growing fields from 400 feet to 1,600 feet. Whitaker said there is not evidence that 1,600 feet is necessary to protect raw, fresh produce from becoming contaminated by CAFOs. Work between the LGMAs, another trade group called Western Growers, and cattle organizations is ongoing, Whitaker said. 

Another recurring theme in Monday’s web presentation was the health of the romaine industry and the larger fresh produce industry.

McEntire said it is misleading to say that the fresh produce industry doesn’t have good traceability. She said traceability issues exist along the entire supply chain, not just on the shoulders of the fresh produce entities along the way. She also said the study group tasked with reviewing traceability issues didn’t talk about block chain technology.

A voluntary program called the Produce Traceability Initiative (PTI), launched in recent years by a coalition of industry groups, has been adopted by some companies, McEntire said.

Better traceability would not only enhance public health, but it could protect businesses that could prove their products were not the ones involved in an outbreak.

“I sure hope if we have traceability, … we won’t have broad advisories,” McEntire said, referring to government warnings just before Thanksgiving a year ago when details of an outbreak were released. The warnings were against all romaine because the FDA could not decipher the bits and pieces of shipping and receiving records that were available. 

McEntire said having better traceability would protect growers whose produce isn’t implicated. The recall of romaine or any other commodity from growers whose products can be traced to illnesses would be to the benefit of all parties, from growers to consumers, she said.

• Review food safety plans and ensure that they include CCPs, preventive controls such as supplier verification and recall plans, and PRPs.
• Ensure sufficient documentation exists for every aspect of the decision-making process that identifies what is a CCP, PC, and PRP.
• Conduct a mock inspection of your facility to gauge preparedness and assess whether staff knows where and how to access relevant information in a timely manner.

FDA has indicated that it will be developing multiple guidance documents to aid the industry in FSMA implementation. In addition, several other groups, such as university Extension offices, consultants, and associations such as the Grocery Manufacturers Association, are launching comprehensive education and training programs as a resource to assist companies in filling the gaps that might be identified.

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